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sd-10-EFTA01356671Dept. of JusticeOther

EFTA Document EFTA01356671

To: Funda Bozkurt Cc: Thomas Klemm < >; Ian Salters < II> Subject: FW: Client OTC derivatives trading with CIB Classification: For Internal use only As regards the process: 1. Please see population attached. 2. Opt Up process mapped out already (I have sent the information to cover this) 3. Remove the delta process as WM clients are being fully onboarded in GM 4. We will not be creating separate KOP's; 5. Brexit requirements: • Remediate KYC for WM & IWP clients to meet CIB stan

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sd-10-EFTA01356671
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To: Funda Bozkurt Cc: Thomas Klemm < >; Ian Salters < II> Subject: FW: Client OTC derivatives trading with CIB Classification: For Internal use only As regards the process: 1. Please see population attached. 2. Opt Up process mapped out already (I have sent the information to cover this) 3. Remove the delta process as WM clients are being fully onboarded in GM 4. We will not be creating separate KOP's; 5. Brexit requirements: • Remediate KYC for WM & IWP clients to meet CIB stan

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To: Funda Bozkurt Cc: Thomas Klemm < >; Ian Salters < II> Subject: FW: Client OTC derivatives trading with CIB Classification: For Internal use only As regards the process: 1. Please see population attached. 2. Opt Up process mapped out already (I have sent the information to cover this) 3. Remove the delta process as WM clients are being fully onboarded in GM 4. We will not be creating separate KOP's; 5. Brexit requirements: Remediate KYC for WM & IWP clients to meet CIB standards Resend new ADL to letter to all clients (when redraft agreed) Understand any further needs (e.g. London Terms of Business) Clarify if Natural Persons can be moved to FFT, London have agreed to unwind risk when required. Can I suggest we close this point and then open a new one based on our present plan of action. Thomas —welcome your thoughts? Regards Ian From: Funda Bozkurt Sent: Friday, February 15, 2019 9:52 AM To: Victoria Bruce < >; Thomas Klemm Olivier Poncet < >; Ian Salters >; Steven Mattus >; >; Andrea DeMar < ; Kimberl Hart >; Puzant Merdinian < >; Bill King < >; Jeffrey Roth < Subject: RE: Client OTC derivatives trading with CIB (I) Classification: For Internal use only Please see below for the SII entered in Dec 2018. The due date is 04- June — 2019. The item is part of NFRC . Ian Salters is the IRM, Thomas Klemm is the MGT. - SII - Over the counter products executed through GM platforms CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0042658 CONFIDENTIAL SONY GM_00188842 EFTA01356671

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Subject: FW: Client OTC derivatives trading with CIB [I] From: Funda Bozkurt ‹ > Date: Fri, 15 Feb 2019 17:33:04 -0500 To: Ian Salters Thomas Klemm Cc: Kimberly Hart Classification: For internal use only Ian, I received your email around the Opt up process in PDFs. It is quite helpful. May I see the desk's KOPs and Ellenoi's/Nina's procedures? It should not be a separate process, but the new process should be inserted to WM GM procedures. Please attach the action plan to the SII in D

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